motion to strike jury demand and memorandum of … to strike jury demand and memorandum of law in...

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

HARD CANDY, LLC,

Plaintiff

v.

ANASTASIA BEVERLY HILLS, INC.,

Defendant

Civil Action No. 1:16-cv-21203-KMW

Motion to Strike Jury Demand and Memorandum of

Law in Support

Alan G. Greer

Florida Bar No. 123294

Mark A. Romance


Nathaniel M. Edenfield


RICHMAN GREER, P.A.

North Tower – 14th Floor

396 Alhambra Circle

Miami, FL 33134

(305) 373-4000

(305) 373-4099 (fax)

[email protected]

[email protected]

[email protected]

Louis T. Pirkey

(admitted pro hac vice)

Travis R. Wimberly

(admitted pro hac vice)

PIRKEY BARBER PLLC

600 Congress Ave., Suite

2120

Austin, TX 78701

(512) 322-5200

(512) 322-5201 (fax)

[email protected]

[email protected]

Counsel for Defendant Anastasia Beverly Hills, Inc.

Case 1:16-cv-21203-KMW Document 66 Entered on FLSD Docket 04/19/2017 of 14

mailto:[email protected]





i

TABLE OF CONTENTS

Introduction ................................................................................................................... 1

Facts ............................................................................................................................... 1

Argument ....................................................................................................................... 3

I. There is no right to a jury under the Lanham Act. ........................................... 3

II. Plaintiff has no Seventh Amendment right to a jury in this case. ................... 3

A. Disgorgement of profits is an equitable remedy, not a legal

remedy. ..................................................................................................... 5

B. An injunction is an equitable remedy, not a legal remedy. .................... 8

C. The Court—not a jury—decides whether to award costs and

attorney fees. ............................................................................................ 8

III. A bench trial better fits this case. ...................................................................... 8

Conclusion .................................................................................................................... 10

Certificate of Compliance with Local Rule 7.1 ........................................................... 11

Certificate of Service .................................................................................................... 12


1

INTRODUCTION

Plaintiff has no right to a jury in this case. Neither the Lanham Act nor the

Seventh Amendment give Plaintiff that right. Having withdrawn its claim for

damages a few weeks ago, ECF Nos. 50 & 51, Plaintiff’s remaining claims are

equitable—not legal—in nature. Equitable claims are tried to the Court, not to a jury.

The Court should strike Plaintiff’s jury demand.

FACTS

This is a lawsuit for trademark infringement and unfair competition. See

generally ECF No. 1 (“Complaint”). Both parties are in the cosmetics business.

Plaintiff’s allegations stem from a product formerly sold by Defendant Anastasia

Beverly Hills, Inc., called the “Gleam Glow Kit”:

Fig. 1: Gleam Glow Kit (front cover)

Fig. 2: Gleam Glow Kit (back cover)


2

Fig. 3: Gleam Glow Kit (inside)

ECF No. 39-1 [D’s Depo. Exh. 17].

As these photos show, the Gleam Glow Kit contained four shades of makeup.

Anastasia named the four shades Hard Candy, Mimosa, Starburst, and Crushed

Pearl. Plaintiff alleges that one of these four shade names—Hard Candy—infringed

its trademark rights. Complaint ¶ 17. Plaintiff brings two claims under the federal

Lanham Act and two claims under state common law. Id. ¶¶ 24-51.

Initially, Plaintiff sought damages. But a few weeks ago, Plaintiff withdrew its

damages claim. ECF Nos. 50 & 51 (March 27 stipulation and order). With no claim

for damages, Plaintiff now seeks (1) disgorgement of Anastasia’s profits earned on

the Gleam Glow Kit; (2) the costs of the action; and (3) attorney fees. Id.; see 15 U.S.C.

§ 1117(a). Plaintiff also presumably seeks a permanent injunction (see Complaint p.

13 ¶ C), though as discussed below, that request is basically moot.


3

ARGUMENT

For a civil litigant to demand a jury, it must have the right to one under either

a federal statute or the Seventh Amendment. See Fed. R. Civ. P. 38(a). If neither

source confers that right, the Court should strike any jury demand. See id. 39(a)(2).

Here, Plaintiff has demanded a jury, but it has no federal right to one. The

Lanham Act does not grant that right, and because Plaintiff withdrew its claim for

damages a few weeks ago, neither does the Seventh Amendment. The Court should

strike Plaintiff’s jury demand and try this case to the bench. See id.

I. There is no right to a jury under the Lanham Act.

The first question under Rule 38(a)—whether a federal statute gives Plaintiff

the right to a jury—requires little discussion. It is well-established that the Lanham

Act neither grants nor denies the right to a jury. The Act is “silent” on the issue. E.g.,

Sanijet Corp. v. Jacuzzi Inc., No. Civ. A 3:01CV0897-P, 2002 WL 1398546, at *1 (N.D.

Tex. Feb. 14, 2002). The question here thus turns on the Seventh Amendment.

II. Plaintiff has no Seventh Amendment right to a jury in this case.

The Seventh Amendment provides the right to a jury only “[i]n Suits at

common law.” U.S. Const. amend VII. This language reflects the historical distinction

between courts of law and courts of equity. See Parsons v. Bedford, Breedlove &

Robeson, 28 U.S. 433, 447 (1830). Only the former used juries. See id. Thus, the

Seventh Amendment gives the right to a jury only if the suit is legal in nature. Id. If

the suit is equitable in nature, the Seventh Amendment does not apply. Id.

Crucially, even claims brought under a federal statute—like the Lanham Act

here—can be equitable in nature. See, e.g., Chauffeurs, Teamsters & Helpers, Local


4

No. 391 v. Terry, 494 U.S. 558, 564-65 (1990) (citing Tull v. United States, 481 U.S.

412, 417 (1987)). To determine whether a federal statutory claim is equitable or legal,

the Supreme Court conducts a two-pronged analysis. Id. at 565 (citing Tull, 481 U.S.

at 417-18). First, the Court compares the statutory action to the 18th-century actions

brought in courts of England, to see whether similar actions would have been filed in

the courts of law or the courts of equity. Id. Second, the Court examines the remedies

sought to see whether they are essentially legal or equitable. Id. The second prong is

“more important.” Id.

Here, both prongs lead to the same result. First, before the law-equity merger,

“most trademark actions were brought in equity.” Mark A. Thurmon, Ending the

Seventh Amendment Confusion: A Critical Analysis of the Right to a Jury Trial in

Trademark Cases, 11 Tex. Intell. Prop. L.J. 1, 85 (2002); see also id. at 63-68. This

means most trademark cases “were tried without a jury.” Id. at 85. This was

particularly true where—as here—the plaintiff sought primarily a disgorgement of

the defendant’s profits. See id.

Second, Plaintiff seeks no legal remedy here. The main legal remedy available

in trademark lawsuits—actual damages—exited this case when Plaintiff withdrew

its damages claim on March 27. ECF Nos. 50 & 51.1 The March 27 stipulation

identifies the monetary remedies Plaintiff still seeks: disgorgement of Anastasia’s

1 “[T]he issues, not the pleadings, determine whether a right to a jury trial

exists.” FN Herstal SA v. Clyde Armor Inc., 838 F.3d 1071, 1089 (11th Cir. 2016).


5

profits, costs, and attorney fees. Id. Plaintiff also presumably still seeks a permanent

injunction. None of these remedies are legal ones for a jury.

A. Disgorgement of profits is an equitable remedy, not a legal

remedy.

An award of money is not always a legal remedy. See Terry, 494 U.S. at 570

(citing Curtis v. Loether, 415 U.S. 189, 196 (1974)). This case provides a perfect

example. Disgorgement of the defendant’s profits—the principal relief Plaintiff

seeks—is an equitable remedy, not a legal one. The Supreme Court has said so time

and time again. E.g., Terry, 494 U.S. at 570; Tull, 481 U.S. at 424; Porter v. Warner

Holding Co., 328 U.S. 395, 398-99 (1946). So has the Eleventh Circuit. E.g., Waldrop

v. S. Co. Servs., Inc., 24 F.3d 152, 153 (11th Cir. 1994). And this Court has too—in

trademark cases, no less. E.g., Mycoskie, LLC v. 2013toms.com, No. 14-61551-CIV,

2014 WL 12531313, at *4 (S.D. Fla. July 22, 2014); Playboy Enters., Inc. v. P.K. Sorren

Export Co., 546 F. Supp. 987, 997 (S.D. Fla. 1982).

These decisions should end the analysis. When a trademark plaintiff seeks only

equitable relief, courts (including this Court) have consistently ordered bench trials.2

2 E.g., Fifty-Six Hope Road Music, Ltd. v. A.V.E.L.A., Inc., 778 F.3d 1059, 1074-

75 (9th Cir. 2015); Ferrari S.P.A. v. Roberts, 944 F.2d 1235, 1248 (6th Cir. 1991);

Order Granting Mot. to Strike Jury Demand, ECF No. 160, Ass Armor, LLC v. Under

Armour, Inc., No. 15-Civ-20853 (S.D. Fla. Nov. 18, 2016) (order attached as Exhibit

1); Monster Daddy, LLC v. Monster Cable Prods., No. 6:10-1170-MGL, 2013 WL

3337828, at *17 (D.S.C. July 2, 2013); Empresa Cubana Del Tabaco v. Culbro Corp.,

123 F. Supp. 2d 203, 206-09 (S.D.N.Y. 2000); Ringling Bros. v. Utah Div. of Travel

Dev., 955 F. Supp. 598, 605 (E.D. Va. 1997); G.A. Modefine S.A. v. Burlington Coat

Factory Warehouse, 888 F. Supp. 44, 45-46 (S.D.N.Y. 1995); Partecipazioni Bulgari,

S.p.A. v. Meige, No. 86-2516-CIV, 1988 WL 113346, at *3-4 (S.D. Fla. May 23, 1988);

Am. Cyanamid Co. v. Sterling Drug, Inc., 649 F. Supp. 784, 788-89 (D.N.J. 1986).


6

Many of these trademark decisions have made quite explicit that a claim for

disgorgement of profits does not trigger the Seventh Amendment:

• “There is no Seventh Amendment right to have a jury calculate

profits.” Fifty-Six, 778 F.3d at 1074.

• “[T]he disgorgement of defendant’s profits . . . [is] wholly equitable

and do[es] not create a constitutional jury trial right.” Ringling Bros.,

955 F. Supp. at 605.

• “The crux of the issue presented here is whether or not a claim for

disgorgement of profits in a trademark case constitutes a claim for

damages entitling the defendant to a jury trial. . . . [The defendant]

is not entitled to a jury trial and its demand is hereby stricken.”

Empresa, 123 F. Supp. 2d at 206, 213.

• “[I]n the trademark infringement context, the remedy of

disgorgement of profits is equitable in nature.” G.A. Modefine, 888 F.

Supp. at 45 (denying request for jury trial).

• “Ferrari’s complaint requested only equitable relief[:] an injunction

and disgorgement of profits.” Ferrari S.P.A., 944 F.2d at 1248

(affirming denial of jury trial).

• “The relief admittedly sought . . . is equitable in nature or otherwise

in the province of the court—primarily the recovery of Monster

Daddy’s profits (under the Lanham Act) and attorney’s fees as a

prevailing party.” Monster Daddy, 2013 WL 3337828, at *17 (striking

jury demand).

In the interest of candor, Anastasia notes that a “small minority” of older

district court decisions—none from this Court—reached a different result.3 6 J.

Thomas McCarthy, McCarthy on Trademarks & Unfair Competition § 32:124 (4th ed.

2014) (treatise excerpts attached as Exhibit 2). But those outlier decisions do not

change the result here.

3 E.g., Oxford Indus, Inc. v. Hartmarx Corp., 15 U.S.P.Q. 2d, 1990 WL 65792

(N.D. Ill. 1990); AMF Inc. v. Nat’l Boat Works, Inc., 192 U.S.P.Q. 81, 1975 WL 21202

(M.D.N.C. 1975).


7

First, they are wrong. As higher courts and influential commentators have

explained, the minority decisions rest on an incorrect reading of Dairy Queen, Inc. v.

Wood, 369 U.S. 469 (1962). See, e.g., McCarthy, supra, § 32:124. In Dairy Queen, the

Supreme Court held that a licensee was entitled to a jury trial on legal claims. 369

U.S. at 478-80. The minority decisions misread Dairy Queen as involving a claim for

disgorgement of profits, when actually it involved two indisputably legal remedies:

damages for breach of contract, and damages (not disgorgement of profits) for

trademark infringement. See id. at 476-77. Many courts have observed the correct

reading of Dairy Queen, including the Eleventh Circuit. E.g., Fifty-Six, 778 F.3d at

1075; Gucci Am., Inc. v. Li, 768 F.3d 122, 132-33 (2d Cir. 2014); Phillips v. Kaplus,

764 F.2d 807, 814 (11th Cir. 1985).

Second, the minority decisions are not binding. Neither this Court nor the

Eleventh Circuit has held that disgorgement of profits is a legal remedy triggering

the right to a jury. As just noted, the Eleventh Circuit has rejected that interpretation

of Dairy Queen. See Phillips, 764 F.2d at 814 (affirming this Court’s denial of a jury

trial and explaining that, unlike the equitable remedy of a profits accounting, Dairy

Queen involved what was “really a legal claim for breach of contract”). The binding

law is unmistakable: disgorgement of profits is an equitable remedy. See supra p. 5.

Finally, the minority decisions are stale. More recent decisions have taken the

majority view. See supra p. 5 n.2. This makes sense. In the decades since Dairy Queen,

the Supreme Court has repeatedly said that disgorgement of profits is an equitable

remedy, not a legal one. E.g., Terry, 494 U.S. at 570; Tull, 481 U.S. at 424.


8

B. An injunction is an equitable remedy, not a legal remedy.

Although not mentioned in Plaintiff’s March 27 stipulation (ECF No. 50),

Plaintiff will presumably seek a permanent injunction if it wins at trial. This is the

“usual” remedy (and often, the only remedy) for a plaintiff in a trademark case.

5 McCarthy, supra, § 30:1.

An injunction in this case would basically be moot. Anastasia stopped selling

the Gleam Glow Kit over half a year ago, and it will not sell the kit again. Also, while

Anastasia does not agree that it infringed Plaintiff’s rights, Anastasia will not use

the words Hard Candy again (and has confirmed this to Plaintiff’s counsel on the

record). But regardless, “[i]njunctive relief is an equitable remedy.” Grayson v. Allen,

491 F.3d 1318, 1322 (11th Cir. 2007). “[T]here is no constitutional right to a jury trial

on a claim for an injunction.” 9 Charles A. Wright & Arthur R. Miller, Federal Practice

& Procedure § 2308 (3d ed. 2008).

C. The Court—not a jury—decides whether to award costs and

attorney fees.

If Plaintiff wins at trial, it intends to seek costs and attorney fees. ECF No. 50.

Neither issue goes to a jury. They are issues for the Court to decide after trial (and

only if Plaintiff wins, which Anastasia believes is unlikely). See, e.g., CBS Broad., Inc.

v. EchoStar Commc’ns Corp., 450 F.3d 505, 518 n.25 (11th Cir. 2006); Partecipazioni

Bulgari, 1988 WL 113346, at *3.

III. A bench trial better fits this case.

Because Plaintiff has no federal right to a jury, its jury demand is improper.

The Court’s analysis can end there. See Fed. R. Civ. P. 38(a), 39(a)(2).


9

However, the Court may also wish to consider the practical benefits of a bench

trial. All the usual benefits apply: the trial will be shorter and more efficient,

members of the community will not have to sacrifice time and money to serve on a

jury, and the parties will both probably end up saving money (and time) in trial costs

and attorney fees.

A bench trial will also reduce the Court’s pretrial workload. For example, some

of the parties’ Daubert arguments will become moot,4 the Court will not need to

review and approve proposed jury instructions, and it will not need to decide any

motions in limine. See, e.g., Singh v. Caribbean Airlines Ltd., No. 13-20639-CIV, 2014

WL 4101544, at *1 (S.D. Fla. Jan. 28, 2014) (“[T]his is a bench trial, making any

motion in limine asinine on its face.” (quotation omitted)).

Likewise, a bench trial will better promote judicial economy. Plaintiff seeks no

remedy that a jury alone could award. See supra Part II. Even if this case were tried

to a jury (and even if Plaintiff won the trial), the Court would still need to

independently decide whether to award any of Anastasia’s profits—and how much, if

so. See 15 U.S.C. § 1117(a) (profits awards are “subject to principles of equity,”

“assessed” by the Court or under the Court’s direction, and subject to the Court’s

authority to “enter judgment for such sum as the court shall find to be just, according

4 Both parties have moved to exclude an opposing expert witness. ECF Nos. 44

& 45. These Daubert cross-motions argue, among other things, that the two experts’

testimony will confuse and mislead the jury under Federal Rule of Evidence 403. ECF

No. 44 at 12; ECF No. 45 at 19-20. If the Court grants this motion to strike the jury

demand, Anastasia will withdraw as moot its Rule 403 argument against Plaintiff’s

expert (though the Court should still exclude him for all the other reasons outlined

in Anastasia’s Daubert motion, ECF No. 45 at 1-18).


10

to the circumstances of the case”); see also ECF No. 64 at 1 (Plaintiff’s concession that

the Court has final say on awarding profits).

A bench trial eliminates this inefficiency. The Court can decide all the issues

in one fell swoop. If it finds for Plaintiff on liability, it can decide at the same time

whether to award any of Anastasia’s profits. This authority has always belonged to

the courts (not to juries), long before the Lanham Act codified it:

[The trademark law] does not stand for the proposition that an

accounting [of profits] will be ordered merely because there has been an

infringement. Under the Trade Mark Act of 1905, as under its

predecessors, an accounting has been denied where an injunction will

satisfy the equities of the case.

Champion Spark Plug Co v. Sanders, 331 U.S. 125, 131 (1947) (affirming district

court’s and court of appeals’ decisions not to award profits).

Judges “regularly” handle profits determinations in trademark cases. Fifty-

Six, 778 F.3d at 1075-76. Juries traditionally do not. Id. “[T]he determination of

profits under § 1117 is not ‘fundamental . . . inherent in and of the essence of the

system of trial by jury.’” Id. (quoting Tull, 481 U.S. at 426). So too here.

CONCLUSION

Plaintiff has no right to a jury trial. The Court should strike Plaintiff’s jury

demand and try this case to the bench.


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CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1

Under L.R. 7.1, Defendant’s counsel conferred with Plaintiff’s counsel in a

good-faith effort to resolve the issues raised in this motion. The parties have not been

able to resolve the issues, and Plaintiff has not consented to the relief sought.

DATED: April 19, 2017

s/ Mark A. Romance

Alan G. Greer


Mark A. Romance


Nathaniel M. Edenfield


RICHMAN GREER, P.A.

North Tower – 14th Floor

396 Alhambra Circle

Miami, FL 33134

(305) 373-4000

(305) 373-4099 (fax)

[email protected]

[email protected]

[email protected]

Respectfully submitted,

s/ Travis R. Wimberly

Louis T. Pirkey (admitted pro hac vice)

Travis R. Wimberly (admitted pro hac

vice)

PIRKEY BARBER PLLC

600 Congress Ave., Suite 2120

Austin, TX 78701

(512) 322-5200

(512) 322-5201 (fax)

[email protected]

[email protected]

Counsel for Defendant Anastasia Beverly Hills, Inc.







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CERTIFICATE OF SERVICE

I hereby certify that on April 19, 2017 a true and correct copy of the foregoing

document was electronically filed with the Clerk using the CM/ECF filing system and

served upon on all counsel of record or pro se parties below, either via transmission

of Notices of Electronic Filing generated by the CM/ECF filing system or in some

other authorized manner for those counsel or parties who are not authorized to

receive electronically Notices of Electronic Filing:

Kevin Kaplan

Gabriel Groisman

COFFEY BURLINGTON, P.L.

2601 South Bayshore Drive, Penthouse 1

Miami, Florida 33133

Tel: 305-858-2900

Fax: 305-858-5261

[email protected]

[email protected]

[email protected]

[email protected]

Counsel for Plaintiff Hard Candy, LLC

s/ Mark A. Romance

Mark A. Romance





EXHIBIT 1

Case 1:16-cv-21203-KMW Document 66-1 Entered on FLSD Docket 04/19/2017 Page 1 of 4

1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 15-Civ-20853-COOKE/TORRES

ASS ARMOR, LLC, et al., Plaintiffs, v. UNDER ARMOUR, INC., Defendant. ______________________________________/

ORDER ON DEFENDANT’S MOTION TO STRIKE JURY DEMAND

This matter is before the Court on Defendant’s Motion to Strike Jury

Demand [D.E. 140]. After careful consideration of the motion, response, reply, sur-

response, and relevant authority, and for the reasons discussed below, Defendant’s

Motion to Strike Jury Demand is GRANTED.

I. ANALYSIS

On September 13, 2016, Under Armour, Inc. (“Defendant”) filed a Motion to

Strike Jury Demand against Ass Armor, LLC, et al. (“Plaintiffs”). Because

Defendant recently dropped its claim for monetary damages1 on September 7, 2016

to streamline trial, Defendant argues that only equitable claims remain and that

there is no right to a jury trial. In Plaintiffs’ sur-response, Plaintiffs concede that

1 Defendant’s counterclaim initially sought both equitable relief – an injunction and disgorgement of Plaintiffs’ profits – and monetary damages. [D.E. 39].

Case 1:15-cv-20853-MGC Document 160 Entered on FLSD Docket 11/18/2016 Page 1 of 3Case 1:16-cv-21203-KMW Document 66-1 Entered on FLSD Docket 04/19/2017 Page 2 of 4

2

“there is no statutory or constitutional right to a jury” because both parties only

seek equitable relief on their claims. [D.E. 149]. But, Plaintiffs urge the Court to

proceed with a jury trial because Plaintiffs will suffer prejudice by Defendant’s

continued gamesmanship. Since this litigation began, Plaintiffs contend that they

have always prepared for a jury trial and that Defendant’s sudden decision to drop

its damage claim is too prejudicial.

On September 28, 2016, the Court required Plaintiffs to file a sur-response to

address why the Eleventh Circuit’s decision in FN Herstal SA v. Clyde Armory Inc.,

838 F.3d 1071 (11th Cir. 2016) “does not strongly support the grant of this motion to

strike jury demand.” [D.E. 147]. In FN Herstal SA v. Clyde Armory Inc., both

parties initially demanded a jury trial but their damage claims were later dropped –

leaving both parties with only claims for equitable relief. The district court

subsequently granted plaintiff’s motion to strike the jury demand. The Eleventh

Circuit affirmed the district court’s decision and reasoned:

When no right to a jury trial exists and where no prejudice will result, a party may unilaterally withdraw its consent to a jury trial. We are . . . persuaded by the Fifth Circuit’s discussion in Armco, in which the defendant demanded a jury trial based on the plaintiff's claims for legal relief—trademark infringement damages. 693 F.2d at 1158. The plaintiff moved to strike the defendant’s jury demand “[o]n the eve of trial” because the plaintiff no longer sought legal relief. Id. . . . This Court has affirmed a district court’s striking a jury demand “days before trial” without any consideration of prejudice because no right to a jury existed where only equitable relief was sought. See CBS Broad., Inc., 450 F.3d at 517 n.25. The district court correctly granted FN’s motion to strike the jury demands.


3

FN Herstal SA, 838 F.3d at 1089-90.

Here, Plaintiff attempts to distinguish FN Herstal SA on the basis that the

Eleventh Circuit found that “no prejudice will result”. Id. at 1089 (emphasis added).

This case is allegedly distinguishable because Plaintiffs here have been prejudiced

by Defendant’s continued gamesmanship during the pendency of this entire

litigation and will continue to be prejudiced if this case proceeds to a bench trial.

Plaintiffs refer the Court to many reasons why prejudice may result – ranging from

discovery costs in excess of $60,000 to unnecessary expert reports. But, Plaintiffs’

entire argument is premised on speculation that Defendant is attempting to “make

this litigation as expensive as possible.” [D.E. 149]. Plaintiffs present no concrete

argument to substantiate its claim that prejudice will result with a bench trial.

And the timing of Defendant’s motion is no bar because the Eleventh Circuit has

previously affirmed district courts striking jury demands “days before trial.” CBS

Broad., Inc. v. EchoStar Commc’ns Corp., 450 F.3d 505, 517 (11th Cir. 2006).

II. CONCLUSION

For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that

Defendant’s Motion to Strike Jury Demand [D.E. 140] is GRANTED.

DONE AND ORDERED in Chambers at Miami, Florida, this 18th day of

November, 2016.

/s/ Edwin G. Torres EDWIN G. TORRES United States Magistrate Judge


EXHIBIT 2


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